Managing subcontractors on a construction project adds another complication to risk management at the site. Effective management of subcontractors OHS performance can sometimes be overlooked because subcontractors:
may only be on site for a short time and are
wrongly thought to pose little or no risk may be wrongly considered as solely responsible for their own actions and consequences
may work in isolation from the main project
activities
risk exposure may not be considered as part of
the overall site risks
may not know what their responsibilities are in
risk management
may not be committed to risk controls, and
may take unnecessary risks, to cut costs and
increase profits.
The RTA may refuse approval for the use of a
subcontractor on the basis of the above information.
3 steps for managing subcontractors
Keeping control over subcontractors involve three main steps for the Principal Contractor:
their own people are working safely, and
their subcontractors are also working safely.
Selection and approval to use
subcontractors
obtain written approval from the RTA to
subcontract any part of the work to be done
obtain written approval from the RTA prior to
engaging each subcontractor, and
can show they are competent to do the
job, and
have demonstrated risk treatment
measures.
Only allow subcontractors on site who:
have undertaken the three levels of induction general industry, work activity and site specific.
Monitor subcontractors risk management
processes to ensure they are:
doing things according to plan, and
working to their safe work method
statements.
What the principal contractor must do
Under Part 8.3 of the OHS Regulation 2001 the principal Contractor must:
give a subcontractor those parts of the OHS
Management Plan for the site which are relevant to the work the subcontractor will be doing before the subcontractor starts work
if changes are made to the Plan which are
relevant to the work the subcontractor is doing, the Principal Contractor must make sure the subcontractor gets a copy of the relevant changes
assess whether the subcontractor requires a
safe work method statement for the work to be undertaken
Under the RTAs General Conditions of Contract,
the Principal Contractor must:
Select subcontractors who:
The risk management process has to be efficiently
managed so effective strategies are in place to eliminate or minimise risk. Under RTA contracts it is the Principal Contractors responsibility to provide effective safety management at the work site. Principal Contractors have to make sure:
provide information about the subcontractors
OHS performance and safe working procedures in the submission to the RTA to use a subcontractor.
make sure the subcontractor has all necessary
safe work method statements for the work the subcontractor will be doing before a subcontractor starts work
direct a subcontractor to follow the safe work
method statements provided and to comply with the requirements of the OHS Act 2000 and the OHS Regulation 2001
monitor the performance of subcontractors to
make sure they are following their safe work method statements and complying with OHS law and regulations
take action where subcontractors arent
following their safe work method statements and complying with OHS law and regulations
direct the subcontractor to stop work where
there is an immediate risk to health and safety until the situation is fixed, and
make sure that for any hazardous substances
brought onto the site by subcontractors:
Part 4.2 of the RTA OHS Contract Specification
(Major Works) backs up these requirements from the OHS Regulation. Under this specification, the Principal Contractor:
must spell out in their OHS Management Plan
the processes they will use for selecting subcontractors and controlling them while they are working on the site
must use safety system requirements in
deciding which subcontractors to use
get subcontractors to submit a site specific
safety plan and safe work method statements for the work they will be doing before they start work (If subcontractors dont have this systems documentation themselves then they can work under the Principal Contractors systems, just so long as this safety documentation is on the subcontractors letterhead.)
must monitor subcontractors performance to
make sure the safety system requirements have been implemented and that the subcontractor work is proceeding without risk, and
include in the OHS Plan for the work, a
program to monitor and document the effectiveness of the safety management systems of all subcontractors working on the site.
- Material Safety Date Sheets (MSDSs) are
provided onto the site by subcontractor, and - they are entered into the hazardous substances register kept at the site.
What subcontractors must do
Part 8.3 pf the OHS Regulation 2001 also sets out responsibilities for subcontractors. Subcontractors must only start work at a construction site when they have:
been given those parts of the site OHS
Management Plan which are relevant to their work
assessed the risks involved in their work
put together written safe work method
statements, which include the risk assessment, and provided these to the Principal Contractor
processes in place to keep safe work method
statements up to date with copies of revisions to the Principal Contractor
provided all their own employees with site
induction
told the Principal Contractor about any
hazardous substances they will bring onto to the site, and
given the Principal Contractor any additional
information they have about the hazardous substance, particularly relating to atmospheric monitoring or medical surveillance.
The RTAs G21 OHS contract
specification minor works Part 2.2 of the RTA G21 OHS Contract Specification (Minor Works) also backs up these requirements from the OHS Regulation. Under this Specification: The Contractor and subcontractors must at all times identify and exercise all necessary precautions for the health and safety of all personsaffected by services under this contract.
The RTAs G22 OHS contract
specification major works RTA Contractor Health & Safety Information Pack - Part 12 - Managing Subcontractors